En180512dma Devon Minerals Plan Responses Future Quarrying–

PTE/12/41 Development Management Committee 6 June 2012

Devon Minerals Plan: Outline of responses to local consultation on Future Quarrying in East and Mid Devon (potential sand and gravel sites)

Report of the Head of Planning, Transportation and Environment

Please note that the following recommendations are subject to consideration and determination by the Committee before taking effect.

Recommendation: It is recommended that:

(i) the Committee notes the outline of responses to the local consultation on potential quarry sites in East and Mid Devon and future work; and (ii) the Member Working Group consider the response and issues raised in detail in developing the Publication version of the Plan, informed by the further work outlined in this report.

1. Summary

1.1 Following Committee approval on 7 March 2012, a local consultation on preferred sand and gravel sites was held from 15 March to 30 April 2012, with an extension beyond of a week (to 7 May 2012). This report summarises the initial findings from this consultation. Assessments of future demand indicate that sites are required to ensure that an adequate supply of sand and gravel is maintained for the period of the Minerals Plan to 2031.

2. Background

2.1 Devon County Council is in the process of producing the Devon Minerals Plan (previously called the Minerals Core Strategy). When adopted, this document will be the basis for protecting our mineral resources, enabling appropriate mineral development and determining minerals planning applications. This plan will cover the period up until 2031 and will replace the Minerals Local Plan (2004).

2.2 The National Planning Policy Framework requires that one of the key issues we need to address in the Devon Minerals Plan is the provision of land-won and other aggregates; for Devon this includes addressing the forecast shortfall sand and gravel over the period to 2031. In February 2011 a consultation was carried out asking views on potential broad locations for future extraction from the strategically important Budleigh Salterton Pebble Beds for sand and gravel. After reviewing responses to this consultation, the County Council considered that potential sites should be identified and explored in the northern and southern parts of this resource (within East Devon and Mid Devon). To understand the potential implication of mineral working in these two broad areas, 21 potential quarry sites were identified and appraised by Devon County Council officers.

2.3 Before appraising the sites, a detailed methodology for this work was produced and circulated for a focused consultation with key stakeholders between 22 August and 12 September 2011. This provided statutory consultees, local organisations, Devon’s Local Planning Authorities and neighbouring Mineral Planning Authorities the opportunity to comment on the site appraisal methodology. Comments received were considered and incorporated into the methodology before its application. In January 2012, initial findings of the appraisal work were circulated to statutory consultees (including the Environment Agency) and local organisations (e.g. conservation groups) for comment before the public consultation commenced. Comments were received back from Natural England, Devon Wildlife Trust and the RSPB and addressed in the appraisals.

2.4 As an outcome of the initial site appraisal, a preferred site in East Devon (Straitgate Farm, Ottery St Mary – S7) and cluster of preferred sites in Mid Devon (Penslade Cross, Uffculme – N6 and N8) formed the focus of the consultation exercise. The list of suggested excluded sites was also consulted on.

3. Consultation

3.1 The consultation on the sand and gravel sites ran from 15 March to 30 April 2012, with an extension beyond of a week (to 7 May 2012). To advertise the event a purposely designed postcard was sent to every address point within 250m of the 21 sites appraised, with over 470 postcards being sent out. An email notification of the consultation event was also sent to our Minerals Planning consultation database, including organisations and individuals who are registered as having an interest in minerals planning in Devon. These consultees included statutory bodies (e.g. Environment Agency, Highways Agency, District Councils etc), Parish Councils near the sites, and local residents/organisations who had previously participated in consultations.

3.2 The consultation was also publicly advertised. A press release was sent to the local media, and the consultation and events were also advertised online through the homepage of Devon County Council’s website and its ‘consultation finder’ facility. The Parish Councils and libraries nearest the preferred sites also were provided with notices to display on public notice boards, advertising the consultation and drop-in events.

3.3 Two drop-in events were arranged near to the sites in the consultation. The first, proximal to the southern collection of sites, was held on Tuesday 27 March 2012 at West Hill Village Hall, from 4.30pm-7.00pm. The second was held on Thursday 5 April 2012 at The Square Corner, Uffculme, from 4.30pm-7.00pm, focused on the northern sites. This second date was chosen in discussion with the Parish Council, so the event could dovetail with the parish meeting arranged in the same building immediately after. In addition to presenting at the parish meeting at Uffculme, an officer also attended and presented at the Ottery St Mary Town Council meeting held on 2 April 2012.

3.4 For the drop-in events key components of the consultation leaflet were provided on display boards (including maps etc) with staff available to answer questions. Copies of the consultation leaflet and paper response forms were provided for people to take away. Attendance at the two drop in events and parish meetings was high, with over 70 residents attending the Uffculme drop-in event, in excess of 150 residents at the West Hill event and 130 members of the public at the Ottery St Mary Town Council meeting.

3.5 As well as arranging local events in the communities affected, a special meeting of the Development Management Committee was held on 26 April 2012 to allow representatives of those communities to express their concerns directly to Members. A total of 16 speakers presented their objections and concerns over two and a half hours, including district and county councillors and representatives of town/parish councils and local action groups, with a large number of spectators.

4. Responses

4.1 The Future Quarrying in East and Mid Devon consultation received 482 responses, through the online consultation portal, paper response forms, letters and emails. In addition to responses from the general public and local organisations, the Environment Agency, Natural England, Western Power and the Highways Agency also responded to the consultation 1. The 478 responses from local organisations and residents can be broken down by postcode area:

EX11 (Ottery St Mary area) 317 EX15/16 (including Uffculme and Burlescombe) 102 EX5 (including Talaton, Whimple and Aylesbeare) 31 Other 28

4.2 The Council also received two petitions. The first was signed by 151 Thorn Farm Estate residents in Ottery St Mary concerned by the potential of increased flooding if the preferred southern site was progressed. The second petition, opposing “a new and unnecessary quarry at Straitgate Farm which will have detrimental affects on the district and no advantages”, was signed by 37 residents, mainly from West Hill.

4.3 A summary of the responses received is included in Appendices A, B and C. Full versions of the comments received are available at: http://devoncc.limehouse.co.uk/portal/minerals_and_waste_development_framework/ minerals/mineral_sites/sand_and_gravel_site_consultation

5. Outline of Issues Raised

General Points

5.1 For both the northern and southern sites, requests were made by respondents for further survey work/assessments to more fully assess the potential implication of working the sites. Devon County Council is in the process of completing its Sustainability Appraisal and the findings of this work will be incorporated into information gathered from the consultation. As outlined in Section 6 below, further discussion is taking place with consultees on the need for further information on the impacts prior to decisions being made on inclusion of the preferred sites in the Minerals Plan.

5.2 A number of respondents challenged Devon County Council’s assessment of sand and gravel need, highlighting the availability of enough reserves with planning permission for the plan period, declining demand and the contribution of recycled aggregates.

5.3 A number of comments were received stating that there was poor advertisement of the consultation. As highlighted in Section 3, endeavours were made to ensure local residents were aware of the consultation, including direct notification of those living close to potential sites. The total number of responses was significantly higher than any previous consultation on any component of the Devon Minerals Plan.

Preferred Site Penslade Cross, Uffculme – N6 and N8 (see Appendix A for more detail)

1 A response from East Devon District Council is expected

5.4 Three parish councils, one action group and 125 individuals/organisations objected to the potential of mineral extraction in this area. The most commonly cited concern was the impact on traffic/road safety, followed closely by comments regarding potential noise, dust, light pollution, vibration and general pollution. Other concerns included:

Proximity to residential properties, businesses and other sensitive receptors. Landscape and visual impact. Impact on the wildlife/environment. The negative impact on property prices. The cumulative effect of the proposal, with an existing mineral site, landfill and industrial uses nearby. Concern was also raised regarding the potential impact of the Devon Waste Plan on the area. Water impacts, including flooding, dewatering, pollution and impact on private water supplies. The risk of providing the potential for further landfill in the area. Loss of agricultural land and countryside. Long term negative effects on the local economy/nearby settlements. Impacts on public rights of way. Negative impact on existing road layout (with implication for bus and traffic flows in other areas). Impact on historic environment assets.

5.5 Suggestions cited to improve working in the preferred northern area: Screening of the site by trees. Processing material on site. Financial compensation being paid to nearby residents. Working small areas at a time. Guarantee no landfill or bitumen plant.

5.6 188 organisations/individuals supported sites N6 and N8. However, over 153 of these came from residents within postcode area EX11 (Ottery St Mary), with only two from the Uffculme area. In addition, a common misconception from those responding from the southern areas was that N6 and N8 represents an existing quarry area or is an extension to an existing quarry. Mineral workings are present in the vicinity of the site, but these are not physically linked with the potential new working area.

Preferred Site Straitgate Farm, Ottery St Mary – Western part of S7 (see Appendix B for more detail)

5.7 Two parish/town councils, one residents group, two action groups and 370 individuals/organisations objected to the potential of mineral extraction in this area. The Environment Agency also potentially identified the need to object, with concern related to potential harm to biodiversity and the water environment. The most commonly cited concern from all the respondents was the potential impact of working on the water environment, potentially bringing increased flood risk, dewatering, pollution and impact on private water supplies. The second most cited concern was possible traffic and road safety implications; this point was commonly linked to potential routing of traffic to Blackhill Quarry if processing occurred at the nearest existing processing works. Other concerns included:

Impact on the wildlife/environment. Noise, dust, light pollution, vibration and general pollution. Landscape and visual impact. Impact on historic environment assets. Proximity to residential properties, businesses and other sensitive receptors. Inappropriate transportation of material to Blackhill Quarry, prolonging the impact on Woodbury Common. Long term negative effects on tourism/local economy. The site is not large enough to be viable. The northern site represents a better option with opportunity for infrastructure near to working and longevity. Loss of agricultural land and countryside. The cumulative effect of the proposal with other East Devon development, existing sand and gravel sites and the airport. The negative impact on property prices. Constraint on the airport. Risk of providing potential for landfill in the area.

5.8 Suggestions cited to improve working in the preferred northern area:

Not processing at Blackhill – with suggestion of Rockbeare as alternative. Only allow lorry movements out of peak periods. Financial compensation being paid to nearby residents.

5.9 34 organisations/individuals supported the western part of S7. However, 30 of these came from respondents within postcode areas EX15 and EX16 (from the Uffculme and Burlescombe areas).

Excluded Sites (see Appendix C for more detail)

5.10 In general there was overall agreement with intention to exclude certain sites, consistent with the reasons identified from the appraisal process. A significant number of respondents (128) considered the southern area inappropriate for mineral development, with environmental, social and economic sensitivity to this land use.

5.11 Levels of disagreement with the intention to exclude sites were significantly lower. However, comments were received that dismissing sites due to ‘significant harm to the landscape’ and the differentiation of preferred sites from excluded sites was unfounded.

6. Future Work

6.1 In progressing the Minerals Plan towards its Publication stage later this year, further work is being undertaken to address issues raised through the consultation. Key elements of this work include:

(a) The preparation of a consultation report which will be made available online.

(b) Continued engagement with statutory consultees and internal specialist officers to discuss the potential site options in the light of consultation responses, including the need for further information to address issues raised.

(c) Updating the assessment of the future demand for aggregates. A number of respondents challenged Devon County Council’s assessment of sand and gravel need. A new requirement in the NPPF is to undertake a Local Aggregates Assessment, based on a rolling 10 year average of past production, but also taking account of the contribution of alternatives. Further guidance on the Local Aggregates Assessment, is due from Government imminently, which officers will use to prepare an Assessment (in partnership with Plymouth, Torbay and Dartmoor) that will provide evidence for review of this issue.

(d) Holding further discussions with the aggregates industry and the mineral company currently having operational interests in the two preferred sites where necessary to address specific issues arising form the consultation response.

6.2 This work will be reported to the next meeting of the Minerals & Waste Member Working Group.

Dave Black Head of Planning, Transportation and Environment

Electoral Divisions: Willand & Uffculme, Ottery St Mary Rural, Broadclyst & Whimple, Budleigh, Exmouth Halsdon & Woodbury

Local Government Act 1972: List of Background Papers

Contact for enquiries: Andy Hill

Room No. Lucombe House, County Hall

Tel No: (01392) 383510

Background Paper Date File Ref

Have your say on future quarrying in East and Mid Devon March 2012 -

en180512dma sc/cr/devon minerals plan responses quarrying east & mid devon 07 hq 280512 Appendix A To PTE/12/41 APPENDIX A - Preferred Sites Northern Area

Question One – Do you support or object to N6 and N8 as potential sites for sand and gravel extraction?

Question Two – What is the reason for supporting or objecting to the proposal? If you object, what is your greatest concern? Are there any changes that could be made to this proposal that would make it more acceptable?

Respondent Support or Summary of Comments Object Natural Neither at Recognise that sites N6 and N8 have been evaluated within the Northern Area Site Appraisal Report as of low or medium risk in respect of England this stage statutory landscape and biodiversity designations. If more detailed studies confirm this, and demonstrate that avoidance and mitigation measures can be effective, an objection would seem unlikely.

Before making any decisions on whether to allocate these sites we recommend the Council undertakes or requires further studies, including: Landscape and Visual Impact Assessments; hydrogeology reports and more work on the value of the sites for protected species. These studies could serve to verify the impacts upon statutory sites and likely success of mitigation measures. Highways Neither at Development traffic would access the SRN via J27 of the M5. The Agency would need to clearly understand the impact not just at J27 but the Agency this stage distribution of trips along the motorway and through other associated junctions to access destinations in the wider Devon/Somerset area. As you are aware, some of these junctions are already operating at or close to capacity at peak times with predicted traffic growth from developments in Tiverton & Cullompton.

Other comments: The response document should have encouraged comment on a wider and less divisive series of topics. Whilst landscape and biodiversity are important, the Parish Council would have expected greater emphasis to be laid on fragile local communities and their human inhabitants, and in that respect the appraisals are very disappointing. Given the high impact that the proposed sites will have on the local population, consider some of the other sites that warrant further investigation and consideration (away from populated areas). The Parish Council requests that the members of the Development Management Committee should consider the wider future for Uffculme. It is suggested that members should visit the area and talk to local people before making final decisions, and the Parish Council would be happy to escort and guide members to the various sites if this would help. Culmstock Object Object to Northern Site due to dust (prevailing west wind), noise, extra heavy traffic, closure of public right of way (in Prescott), and loss of Parish Council amenity. All of the above factors will have a profound long-term impact on the neighbouring Parish of Culmstock which not only includes a Conservation Area but nestles on the edge of an AONB. Also, experience a lot of impact from the existing Westleigh Quarries. Culm Waste Object Object for the following reasons: and Minerals Proximity to dwellings, farms and businesses – issues with noise and dust associated with quarry workings/vehicles Group Residents’ experience of conveyors is that they are very worst type of background noise Bunds and trees have been found ineffective in protecting residents from noise and dust Lack of local demand for material Existing reserves are available in permitted quarries. Roads are inadequate for traffic carrying trucks from the quarry, landfill and block-works. Also safety implications (including bus stop). Impact on wildlife Loss of agricultural land and impact on organic farms in locality Loss of amenity space and landscape character of area Loss of trees and hedgerows Impact on heritage assets Impact on private water supplies and run-off Risk of smell associated to possible bituminous plant

Other comments: All plant and equipment would have to be dug into any site selected, at least 500m from dwellings and not left on surface behind bunds and trees. Small and more manageable sites should be sought. Advertisement of consultation inadequate. Respondent Support or Summary of Comments Object Individuals/ Object 125 individuals/organisations objected. Organisations Reasons cited for objection Number of times stated Traffic and road safety 66 Noise, dust, light pollution, vibration and general pollution 64 Proximity to properties, businesses, schools and faith buildings (affecting physical/mental health and well-being) 58 Contest need to plan for new sand and gravel quarries, existing reserves sufficient and should be used first 41 Landscape and visual impact 40 Impact on wildlife and environment 28 Negative impact on property prices 25 Cumulative effect of proposal on area with existing site, landfill and industrial uses nearby 23 Water impacts, including flooding, dewatering, pollution and impact on private water supplies 22 Risk of further landfill in area 16 Loss of agricultural land 16 Long term negative impact on local economy/nearby settlements 14 Countryside should be conserved 14 Impact on public rights of way and country access 11 Negative impact existing road layout (implication on bus and traffic flows in other areas) 9 Impact on historic environment assets 6 No reason given 5

Suggestions cited to improve working in the preferred area: Screening of the site by trees Processing material on site Financial compensation paid to nearby residents Working small areas at a time Guarantee no landfill/bitumen plant

The location of the respondents: EX15 54 responses EX16 47 responses EX11 20 responses EX5 5 responses Other 4 responses Ottery Quarry Support Support for the following reasons: Action Group Adjacent to existing mineral workings, with some infrastructure already in place. It is situated adjacent to major roads. A few yards of the A38 connect it to the interchange for the M5 and the North Devon Link Site does not impact on any local tourism. Site does not threaten areas of Ancient Woodland, County Wildlife Sites, Listed Buildings or unique historic manors. Site does not affect essential aquifers, many private, farm and a food company's water supplies, or springs upon which Ancient Woodlands and medieval fishponds rely. CPRE Devon Support Support if need and title proven. Part of land is registered in name of Camas UK Limited. Aggregate Industries claim title, and need to Exeter and demonstrate how. East Devon Group Respondent Support or Summary of Comments Object Aylesbeare Support It has already been used for extraction and all the logistical criteria have been met. Parish Council Straitgate Support Support for the following reasons: Action Group Would meet the shortfall in the Plan without identifying any other site. Good links to the road network via the A38 and M5 without driving through residential areas. Less environmental constraints than the southern sites scoring better in their site appraisals. Next to an existing quarry and landfill site and in the interests of sustainability existing sites and extensions to them should be identified before identifying green field sites. NPPF “Plans should allocate land with the least environmental or amenity value”. Potential for on-site processing plant avoiding the need to transport as-dug material on public roads, NPPF “To support the move to a low carbon future, local planning authorities should: plan for new development in locations and ways which reduce greenhouse gas emissions”. Allows normal economic supply radius. Larger resource for better recovery of on-site plant costs. Well situated for both the Exeter and Taunton areas of growth. Designated an MCA and area of mineral resource for many years. Minimal impact on water having no springs or streams in the vicinity of the site. Minimal impact on groundwater supplies to properties. No airport safeguarding issues. No impact on biodiversity or Ancient Woodland. No impact on listed buildings. No increased flooding risk on downstream community. Offers potential working between different parts of the sites and processing plant, minimising environmental impact of road haulage. Operator intended to move plant to Uffculme from Blackhill in 2008, but postponed due to economic downturn and finishing at Venn Ottery. With quarrying, block works, composting, and landfill all nearby, site would not be out of character with the adjacent industrial activity. Individuals/ Support 184 individuals/organisations supported. Organisations Reasons cited for support Number of times stated Located in area of existing quarrying 123 Good road links/appropriate road options 106 Equipment available at existing quarry/opportunity for it (reducing need to transport material and improving economic viability) 84 Less environmental and highway constraints compared to the southern sites 69 Site well located to areas of growth 60 It is an existing site 32 Size of site provides a long term solution to aggregate supply 24 Few nearby residents/settlements 10 No reason 10 Located adjacent to other industrial uses (brickworks and landfill) 3 Deliverable because owned by Aggregate Industries 1 Using this site will preserve others 1

The location of the respondents: EX11 153 responses EX5 13 responses EX15 2 responses Other 20 responses

Question 3 – Once mineral extraction is complete, it is suggested the site is used for agriculture, nature conservation habitats, woodland and recreation land. Is this proposed after-use acceptable to you? If not, what do you consider to be appropriate at this site and why?

Respondent Summary of Comments Natural England Consider a natural environment after use would be appropriate. It could contribute to meeting the requirements of the National Planning Policy Framework (paragraph 114) that local planning authorities should “set out a strategic approach in their Local Plans, planning positively for the creation, protection, enhancement and management of networks of biodiversity and green infrastructure” . Such an after use could also help offset residual landscape and biodiversity impacts. Highways Agency No objection. CPRE Mid Devon Group Once the extraction is complete, the land should be reinstated for agriculture. The country is rapidly running short of good agricultural land. Burlescombe Parish Council The site, if quarrying took place, would be unsuitable for post agricultural use, it might be suitable for conservation habitats and woodland but those uses could never replace the value to agriculture that N6 and N8 currently provide. It seems far more likely, given that the Broadpath landfill site is approaching its completion, the site will simply become a landfill site. Culmstock Parish Council The site should be returned as near as possible to its current state of natural beauty and the habitat for wildlife restored. Ottery Quarry Action Group In agreement. CPRE Devon Exeter and East Restoration needs to be done properly for agriculture. Devon Group Aylesbeare Parish Council In agreement. Straitgate Action Group In agreement. Individuals/ Organisations 265 individuals/organisations responded

Comment Number of times stated General agreement with restoration scheme proposed 165 Want the site to be left as it is 33 Sceptical the site will ever be restored given length of site life and will be used for landfill/ For those at the time to decide what restoration is appropriate 22 General agreement with restoration scheme proposed – but want guarantee no waste facility in the future 16 General agreement with restoration scheme proposed – but sceptical about quality and timing of restoration 15 Preference for agriculture (with nature conservation measures) 9 Preference for employment use (e.g. golf course, outdoor pursuits) 2 Preference for boating lake/reservoir 2 Preference for woodland 1 Restore site to how it is now 1 General agreement with restoration scheme proposed – but also think potential for landfill should not be ruled out 1

Appendix B To PTE/12/41 APPENDIX B - Preferred Sites Southern Area

Question Four – Do you support or object to the western part of S7 as a potential site for sand and gravel extraction?

Question Five – What is the reason for supporting or objecting to the proposal? If you object, what is your greatest concern? Are there any changes that could be made to this proposal that would make it more acceptable?

Respondent Support or Summary of Comments Object Natural Neither at Concerned about the potential for impacts upon East Devon Heaths SSSI/SPA/SAC and other important natural environment considerations. England this stage More detailed studies are needed. If it is not possible to rule out significant impacts upon statutory landscape and/or biodiversity designations objection from Natural England is likely. Before making any decision on whether to allocate this site we strongly recommend the Council undertakes or requires further studies, including: Landscape and Visual Impact Assessment; hydrogeology report and more work on the value of the site for protected species.

The need for more evidence of hydrogeology and water tables, and potential effects of extraction within both the saturated and unsaturated zone, is something particularly underlined. The Site Appraisal Report identified risks to both statutory and, in particular, non statutory nature conservation sites (e.g. the UK BAP Priority habitat/ancient woodland habitat to the east) as a result of dewatering.

Mitigation for loss of groundwater and disruption of the stream that feeds the ancient woodland might overcome by recharge lagoons. However, we understand the Airport Authority have already expressed significant concerns and recommended against ponds which could attract birds to the vicinity of Exeter Airport, increasing the risk of bird strikes. It is not clear, at this stage, that viable mitigation is feasible for any below water table working.

The consultation explains that extraction method and processing have yet to be established. The only operational plant in the area is situated at Blackhill Quarry within the East Devon Heaths SSSI/SPA /SAC. If processing were to be undertaken here that would raise our level of concern about the potential impacts upon the European site. We recommend the Council ensures that the environmental implications of undertaking processing here are fully understood - including the likely disruption to the agreed restoration programme - and taken into account in deciding whether to allocate the western part of site S7. Highways Neither at Development traffic would access the SRN via either the Daisymount junction or the Patterson Cross junction on the A30. Although Daisymount Agency this stage does not experience capacity issues at present, a number of accidents have occurred at the junction over the latest three year period; Patterson Cross junction provides only limited movements. Adjacent junctions at Turks Head and M5 J29 are all operating at or close to capacity with predicted growth in traffic from planned development East of Exeter and at Honiton. The overall impact of the potential increased number of trips would need to be demonstrated and understood by the Agency.

While the Agency does not, in principle, object to the provision of additional mineral excavation sites in these broad areas, any proposal coming forward must be supported by a detailed transport assessments and where appropriate a package of mitigations measures, complying with current DfT guidance and the requirements of DfT Circular 02/2007: Planning and the Strategic Road Network. Should it be identified that proposals are likely to impact on the function and/or capacity of the SRN, this should be mitigated and necessary funding sought from developers to provide any improvements required. Western Neither at Comments were provided regarding strategic electricity distribution circuits and expectations on developers to mitigate the impact of affecting Power this stage less strategic circuits operating at 11kV or below. Western Power Distribution would normally seek to retain the position of electricity circuits Distribution operating at 132kV and 66kV and in some cases 33kV. Respondent Support or Summary of Comments Object CPRE Devon Neither at More information is needed for S7, including details of title to land, which must be registered with the Land Registry: Exeter and this stage a) Need to be proven in the timescale. East Devon b) Ground water licence needed from EA - S.199 of Water Resources Act 1991. Group c) Beware downstream effect on Cadhay and others. d) Title restriction re effect on adjoining land - shall not prejudice water supplies. e) Aggregate Industries UK Limited ("AI") may claim title to land, but land is not registered. AI need to deduce title and show what specific party actually has title. Environment Likely to Groundwater Agency object Consider the importance and value of this area may be under-represented by the appraisal undertaken so far. Policy on the protection of water resources from changes to aquifer conditions will govern our response to this and every other site. The number of private water supplies suggests that this would be a difficult site to take forward. Similarly, if this area is shown to be a significant part of the catchment for the water features near Cadhay, its deliverability as a viable site would seem unlikely. Biodiversity Disagree with classification of High/Medium risk of harm on Cadhay Bog and Cadhay Wood CWSs, as there will be irreversible and permanent loss of valued asset’s function. We consider that this impact is unacceptable. With regard to Unconfirmed County Wildlife Sites, assessment as to potential for upgrading of Straightway Head UWS to CWS should be carried out prior to determination of preferred sites. Consider potential impact on Cadhay Wood and Cadhay Bog BAP priority habitats as unacceptable where it cannot be mitigated or replaced. In terms of potential to lead to loss or damage of ancient woodland, again, as functionality of these ancient woodlands will be negatively and irreversibly impacted these impacts. Consider this impact is unacceptable. Question whether other dismissed sites have less environmental constraints. Potential mitigation of impacts on S8 ancient woodland (with wetland and bryophyte communities) CWSs might be offered by, for example recharge ponds as an example. For this to stand a chance of working any recharge to the watercourse to supply the CWS will have to mimic a natural hydrograph in perpetuity, to ensure the wetland value of the CWS is supported. It should be confirmed how this will be done and how water quality will also be protected. Would be likely to object to a proposal that cause significant harm to biodiversity and the water environment. In this case the biodiversity value of two CWSs. Water Framework Directive There is no reference to the Water Framework Directive or relevant assessments of this plan that should be made under this Directive. Until this is done we cannot fully assess the impacts of the Plan as we are required to under the WFD. The proposed potential mitigation measures do not mitigate for the negative impacts on water dependent habitats and sites. We suggest that this should be assessed as High Risk (Red). These impacts on the water environment are unacceptable. Flood Risk The whole site is Flood Zone 1. No objections in principle subject to a scheme being submitted for the management of surface water that will safely manage the ‘1 in 100 yr plus climate change’ rainfall for the lifetime of the development. It is important to note that much of the land drains naturally to the east via a minor watercourse that conveys flows towards Coombelake, Cadhay and Ottery St Mary (Thorn Farm Way) where there is a serious risk of residential and commercial property flooding. Any development of this site should seek opportunities to reduce these risks of flooding in line with Objective 14 of the Minerals Appraisal Methodology. Soils Are concerned about the quarry proposals at this site, in particular groundworks, causing widespread soil compaction and run-off. It needs to be ensured that groundworks at the proposed quarry (i.e. vehicle movement, soil removal and stockpiling, hedge removal, compacted tracks and travelling on undisturbed soft grassland) will not cause compaction, or that if compaction is unavoidable, then the run-off from compacted ground is stored in detention ponds. Would like to see some rough calculation carried out on the likely water runoff from say 30 acres of land assuming 80% run-off during a storm event (e.g. a 50mm event). Then could work out if it is feasible to store all this water. Respondent Support or Summary of Comments Object Ottery St Mary Object Object for the following reasons: Town Council Detrimental effects on supplies of water for drinking, dairy farms, the local Catering business and historic fish ponds at Cadhay. Likelihood of increased flooding affecting Cadhay, Coombelake and Thorne Farm Estate which were all badly affected in the October 2008 floods. Quarrying on a greenfield site with major environmental impact, increased pollution and dust. Increased heavy vehicle traffic with adverse effect on the local community as well as safety concerns. Impact on tourism with the proposed quarry site being at the western approach to Ottery St Mary. Having 2 sites (one at Uffculme and one at Straitgate) does not share the impact but doubles the impact. No additional employment would be created. Question whether the quarry is needed on the basis of supply and demand forecast.

Other comment: There are no changes that could be made to this proposal that would make it more acceptable West Hill Object Object for the following reasons: Residents The northern site provides a better longer term option; avoiding massive impacts on thriving agriculture, water supplies, water quality and Association possible flooding, un-thinkable chaos on unsuitable roads and far from life enhancing impacts on the residents of two major conurbations. Contest need to identify site, existing reserves and reduced need for aggregates Massive impact on West Hill – with huge number of heavy lorry movements on inadequate road. Loss of agricultural land is a negative effect on food security and local jobs.

Other comment: Consultation process set up by DCC was less than satisfactory. Ottery Quarry Object Object for the following reasons: Action Group Loss of greenfield site of good productive agricultural land. There are existing reserves at Hillhead Quarry, no need for new quarry. Negative impact on historic assets (Grade 2 listed Devon Longhouse, ancient hedgerows & boundaries and mature native trees and traffic route passing Woodbury Castle). Site has two adjoining areas of Ancient Woodland, Cadhay Wood and Cadhay Bog, which are also County Wildlife Sites and an integral part of the historic Cadhay estate, linked by springs from Straightway. Disruption of water system in and around site (currently aquifer providing private water supplies and feeding fishponds at Cadhay Manor) Increased risk of flooding in Ottery St Mary. The flood relief scheme being carried out at present (at considerable public expense) has taken no account of any unexpected changes, or future disturbances. Noise and dust (affecting residents in West Hill & Ottery St Mary, agriculture and wildlife) Visual impact In appropriate traffic movements on the B3174 (key access road to Ottery) and B3180 (minor road to Blackhill with safety issues). Delayed restoration of Blackhill Negative impact on Ottery’s tourism industry and economy. Respondent Support or Summary of Comments Object Straitgate Object We object on the following grounds: Action Group Safety risk on Exeter airport safeguarding area; there is also a restriction on ponds or bodies of water being developed on site to limit risk of birdstrike. Negative transport impact – processing at Blackhill along the B3180 would reduce road safety, increase pollution, CO2 emissions, and road wear. Delayed restoration of Blackhill, which is within East Devon Pebblebed Heaths recognised to be of European importance for nature conservation designated SPA, SAC as well as AONB and SSSI. Processing plant is incompatible with nature importance of the Heaths and tourism industry. Working of site would increase run-off bringing flood risk (with additional risk posed through climate change) with possible associated pollution risk. Ottery St Mary has history of flooding events associated with the streams from the site, the flood defence scheme being built at Thorne Farm not including an allowance for increased run off associated to quarrying at Straitgate. A Flood Risk Assessment should be completed to show whether increased surface water run-off effects can be mitigated for downstream communities, and that any attenuation ponds required would be compatible with airport safeguarding. The removal of strata at Straitgate and its aquifer properties could impact on surrounding groundwater users (residents, farms and business) in terms of volume of water available or pollution. Two streams originate on the Straitgate site and run through Ancient Woodland and wetland habitats in Cadhay Bog & Cadhay Wood; the latter runs down and eventually supplies the Mediaeval Fish Ponds of Cadhay House (grade I listed). A hydrological impact report should be completed to show whether groundwater supplies can be safeguarded. Prominent hill top position seen widely from the East Hill AONB, and surrounding countryside. Site can be seen from large parts of Ottery St Mary town and parish (including listed buildings). Also visible on tourist route entering Otter Valley. Historic environment will be damaged – fishponds at Cadhay House (Grade 1) fed by stream from Straitgate and setting of Straitgate Farm (Grade II) would be irreparably damaged by surrounding quarrying. Other assets also in area - an archaeology survey would need to be completed before any quarrying took place. Biodiversity impact - there are two areas of Ancient Woodland to the east of Straitgate, designated County Wildlife Sites (CWS), Cadhay Bog and Cadhay Wood fed by water from Straitgate. Veteran trees and hedgerows also would be affected. Quarry (and associated transport of material) will bring negative impacts of noise, dust and pollution to relatively quiet rural and agricultural setting. Scheme will have negative impact on local economy (with loss of agricultural jobs) and a negative impact on tourist industry. The viability of the site has not been appropriate assessed. The site appraisal process was inadequate and unfair (with revision to boundary area of site not appropriately assessed) The site does not have an appropriate access point suitable for HGVs. The consultation was premature and did not provide enough information for the public to make an informed response. Further evidence also required before DCC could assign Straitgate as a strategic site in the Devon Minerals Plan. Alternative more sustainable options for aggregates are available to serve Devon for the plan period. Contest logic of DCC identifying sites in north and south areas as processing of material at Blackhill negates strategy for minimising transportation. Aylesbeare Object Object for the following reasons: Parish Council The overused B3180 road (used to transport aggregates to Blackhill Quarry for processing) is not suitable for this volume of traffic. This road does not have any foundations and is at present carrying 42 tonne trucks from Venn Ottery Quarry to Blackhill Quarry, using the hazardous junction at the Halfway Inn, and causing extensive damage to the road surface and erosion of the road verges and banks. Maintenance of the road causes inconvenience to road users, and recent works have not been adequate to solve issues. Large vehicles have difficultly passing on B3180 slowing the travelling time across the common and bring unwanted dust and fumes to nearby residents. Respondent Support or Summary of Comments Object Individuals/ Object 370 individuals/organisations objected. Organisations Reasons cited for objection Number of times stated Water impacts, including flooding, dewatering, pollution and impact on private water supplies 243 Traffic and road safety 218 Impact on wildlife and environment 186 Noise, dust, light pollution, vibration and general pollution 183 Landscape and visual impact 183 Impact on the B3180 (safety, suitability and disturbance) 149 Contest need to plan for new sand and gravel quarries, existing reserves sufficient and should be used first 147 Impact on historic environment assets 96 Proximity to properties, businesses and schools (affecting physical/mental health and well-being) 90 Inappropriate to process material at Blackhill, prolonging impact on Woodbury Common 79 Long term negative impact on tourism/local economy 72 The site is not a viable option 70 Northern sites present a better option – with existing infrastructure and longevity 54 Countryside should be conserved 37 Loss of agricultural land 21 Cumulative effect of proposal on area with other East Devon development, existing sand & gravel sites and the airport 19 Negative impact on property prices/demand for new homes in area 13 No reason given 4 Constraint on the airport 4 Risk of landfill in area 3 Five further objections were also received citing reasons highlighted above, but no address was provided with the response.

Suggestions cited to improve working in the preferred area: Not processing at Blackhill – with suggestion of Rockbeare as alternative Only allow lorry movements out of peak periods Financial compensation paid to nearby residents

The location of the respondents: EX11 313 responses EX5 30 responses EX15 6 responses Other 26 responses Respondent Support or Summary of Comments Object Individuals/ Support 34 individuals/organisations supported. Organisations Reasons cited for support Number of times stated No reason 18 Few nearby residents/settlements 6 Site well located to areas of growth 5 Good road links/appropriate road options 4 Smaller quarry so less working time and impact on the environment 2 Less environmental and visual impact than other options 2 Adjacent to an already noisy road 1 Northern area already has had its share of mineral extraction 1

The location of the respondents: EX16 17 responses EX15 13 responses EX11 3 responses Other 1 response

Question 6 – Once mineral extraction is complete, it is suggested the site is used for agriculture, nature conservation habitats and woodland. Is this proposed after-use acceptable to you? If not, what do you consider to be appropriate at this site and why?

Respondent Summary of Comments Natural England We consider a natural environment after use would be appropriate. It could contribute to meeting the requirements of the National Planning Policy Framework (paragraph 114) that local planning authorities should “set out a strategic approach in their Local Plans, planning positively for the creation, protection, enhancement and management of networks of biodiversity and green infrastructure” . Such an after use could also help offset residual landscape and biodiversity impacts. Highways Agency No objection. CPRE Devon Exeter and East Restore properly for agriculture. Devon Group Ottery St Mary Town Council In agreement. Ottery Quarry Action Group Yes, but this site should be excluded - it can never be properly 'restored'. Straitgate Action Group 1. Restoration to productive agriculture unlikely to be possible due to changes in soil structures. 2. Restoration involving water would contravene airport safeguarding advice. 3. Restoration to woodland must not create habitats inducing extra birdlife, in line with airport safeguarding advice. 4. Restoration involving landfill would not be possible due to groundwater contamination and extra birdlife contravening airport safeguarding advice. 5. If material was processed at Blackhill, silt would need to be hauled back to Straitgate to allow restoration, against the principles of sustainability. 6. Due to the removal of groundwater storage, attenuation ponds would need to be built into the design to mitigate enhanced run-off from the site in times of extreme rainfall. Any water bodies would however contravene airport safeguarding advice. Aylesbeare Parish Council Hope will not apply. Respondent Summary of Comments Individuals/ Organisations 258 individuals/organisations responded

Comment Number of times stated Want the site to be left as it is 111 General agreement with restoration scheme proposed 99 Sceptical the site will ever be restored given length of site life and will be used for landfill/ For those at the time to decide what restoration is appropriate 16 General agreement with restoration scheme proposed – but sceptical about quality and timing of restoration 15 Preference for nature conservation, woodland and enhanced public rights of way 6 General agreement with restoration scheme proposed – but want guarantee no waste facility in the future 5 Preference for agriculture 5 Restore site to how it is now 2 Preference for employment use (e.g. golf course, outdoor pursuits) 1 General agreement with restoration scheme proposed – but also think potential for landfill should not be ruled out 1

Appendix C To PTE/12/41 APPENDIX C – Excluded Sites

Question Seven – Do you agree with out intention to exclude these sites from further consideration?

Question Eight – What is the reason agreeing or disagreeing with our intention to exclude the sites?

Respondent Agree or Summary of Comments Disagree Highways Neither No further comment to make on the excluded sites. Agency Environment Neither No comments provided but can be provided on request. Agency Uffculme Disagree The Parish Council does not accept that other sites, rejected by the appraisal team as ‘likely to cause significant harm to the landscape’, should be Parish Council so readily dismissed. Individuals/ Disagree 28 individuals/organisations disagreed. Organisations Reasons cited Number of times stated Disagree excluded sites are worse than S7 and N6 & N8 12 Alternative to the whole southern area should be found 6 Too early in process/not enough evidence to dismiss sites 5 Northern sites should be re-examined to see if there is potential for sites away from residential properties 3 No reason 2

Natural Agree (in In the absence of any further information to demonstrate their acceptability in terms of likely natural environment impacts we particularly agree with England part) the exclusion of sites N1, N2 and N11 in Mid Devon and S3, S4 and S8 in East Devon. These were amongst the most notable of sites where significant effects upon statutory landscape and biodiversity designations and other important natural environment considerations could not be ruled out as a result of the Sites Appraisal Reports. Ottery Quarry Agree They are not suitable according to the constraints listed by Devon County Council - nearly all of which apply to S7 as well. Action Group Straitgate Agree The southern area is not able to support on-site processing, has too many problems with water-related issues, flooding and groundwater supplies, Action Group has traffic and airport safeguarding issues and impacts on areas of biodiversity. Aylesbeare Agree Do not think to be necessary. Parish Council Culmstock Agree These sites are even closer to the Parish of Culmstock, and the dust factor would increase the risk to health. Parish Council CPRE Devon Agree Exclude S1-6, S8-10, N1-5, N10-11. Damage to landscape and water resources, and various Access problems, and need retain land for Exeter and Agriculture for Security of Supply. East Devon Group Respondent Agree or Summary of Comments Disagree Individuals/ Agree 260 individuals/organisations agreed. Organisations Reasons cited Number of times stated Southern area is inappropriate for mineral extraction (environmental, social and economically sensitive) 128 No reason 43 For reasons identified in the consultation leaflet 29 To protect the environment (including wildlife and habitats) 26 For the well being of local residents 24 Question the need for more quarries 20 Northern area is inappropriate for mineral extraction (environmental, social and economically sensitive) 9